How to Write an Objection

What Are They Asking For?

 

LBA has submitted a planning application to:

  1. Build a new terminal

  2. Extend Unrestricted Flying Hours by 90 mins (0600 – 2330)

  3. Alter current restrictions on night time flying

 

The purpose of this is to allow an expansion in passenger numbers. LBA claim that the new terminal is essential to accommodate these extra passengers. Equally important to them are extended flying hours which would allow carriers to squeeze in an extra flight each day on many routes, and more night flights.

 

Yikes - This is Complicated!

The planning portal looks daunting, and the application documents appear impenetrable, but don’t despair.

 

Naturally, the application tells a story that says ‘this is wonderful, how could you possibly turn this down?’ The documents also look very slick, but their purpose is to pull the wool over our eyes (and those of the council members on the Plans Panel).

 

Of course, we know that there are many compelling reasons to turn it down, and this is why your objection is so important. Remember that the expansion will pollute the air we breathe and destroy any chance of the city becoming carbon neutral.

 

The amount of detail you can put into an objection depends on the time you have and your level of knowledge. This guide shows how you can make an objection, ranging from the very simple to the very complex.

 

How to make Your Objection

 

First of all, the basics.

 

You can find LBA’s planning application and register to make an objection on Leeds City Council’s website.

 

Then click on the green box: ‘search planning applications using public access’. Enter the LBA application reference number in the box: 20/02559/FU and click on search. This opens LBA’s planning application.

 

Near the bottom of the planning application page, click on ‘make a comment’. This will take you to a registration page which is quick and easy. Then you can go back to the planning application to register your objection by clicking on ‘make a comment’.

 

The current deadline for objections is on the Council website, but we have it in writing that objections received later will be accepted.

 

It’s best to write your objection in a separate document and then paste it into the portal. You can also post an objection, but it’s best to use the portal.

 

Write it Yourself

 

If one thousand people send in identical pre-written post card objections, they will be counted as one objection, so put it in your own words.

 

Keep it Relevant

 

Objections need to be “material” to the application (i.e. relevant). Carbon emissions, noise, air pollution, the economics and road congestion are all material, but the impact on house prices is not (even though there is an impact).

 

The Simple Approach

 

There is plenty of help on our website, giving information that can be used when writing your objection. In particular, look at In Brief - The reasons why you should oppose the Application. You don’t need to be an expert. Rather than trying to say something about everything, work on the areas that matter to you and turn them into good arguments. And you can send in as many objections as you like.

More Detailed Approach

 

This is not as daunting as it might first appear. The next few sections describe an approach you can use.

 

First, we need to cover LBA’s Justification for the Expansion and then something called the Core Strategy SP12.

 

LBA’s Justification

 

It’s useful to understand how LBA justify the need to put forward this application. This is taken from the application:

 

  • LBA is forecast by the Government to have growing passenger demands, with an expectation that the Airport will have a throughput of c. 7mppa by 2030.

  • The need for growing the Airport is underpinned by the Development Plan, and most notably, Policy 12 of the Core Strategy Strategic Review (2019) (CSSR) which supports the growth of the Airport due to its economic benefits to the City and the Region. 

  • In the alternative, doing nothing will fail to achieve the economic potential of the Airport and will not respond to the environmental agenda set by Leeds’s Climate Emergency

 

Now those government figures were a forecast, not a demand, they carry no legal weight. The claim that the expansion is supported by The Core Strategy is important to challenge in your objection. The claim to be responding to the Leeds Climate Emergency is almost laughable and is explored in detail elsewhere on the site.

 

The Core Strategy

 

Applications are assessed against something called The Core Strategy. This is how Leeds City Council sets out the rules for what can be built and includes planning policies. LBA claim that the application fits perfectly with the Core Strategy and, where it doesn’t, they say how they will mitigate the impacts. In particular, the application refers to policy SP12, which covers the airport. So, it’s a good idea for you to refer to the Core Strategy and SP12 as well. This adds weight to any objection. There are other sections in the Core Strategy that cover biodiversity, climate change, etc.

Here are 2 key parts of the Core Strategy:

 

CORE STRATEGY SPATIAL POLICY 12: MANAGING THE GROWTH OF LEEDS BRADFORD
INTERNATIONAL AIRPORT The continued development of Leeds Bradford International Airport will be supported to enable it to fulfil its role as an important regional airport subject to:
(i) Provision of major public transport infrastructure (such as Tram Train) and surface access improvements at agreed passenger levels,
(ii) Agreement of a surface access strategy with identified funding and trigger points,
(iii) Environmental assessment and agreed plans to mitigate adverse environmental effects, where appropriate,
(iv) The management of any local impacts and implementation issues, including visual and highway issues.

 

4.9.12: At international, national and regional levels, airports play an important role as an element of key transport infrastructure. However, air travel raises a number of concerns regarding its impact on climate change through the generation of emissions and also the local impact on the environment (including transport trips). Such issues need to be balanced with overall national objectives and guidance and considered within the context of the Core Strategy.

 

So, SP12 says that development of LBA is supported subject to environmental assessment and mitigation. Well it’s obvious to most of us that the environmental impact is completely unacceptable (whether that be emissions, noise or whatever) and that is what your objection will say, but relating it to SP12 can be very useful.

 

Writing your Detailed Objection

Obviously, the amount of detail you put in depends on how much time you have, but there are a few rules to follow:

 

  1. Explain why you think the expansion is wrong – your own words and feelings.

  2. For the topics that you feel most strongly about use the Galba ‘Objections - in detail’ guides to counter the application - identify the impacts of expansion that you think are unacceptable.

  3. Mention SP12 of the Core Strategy (continued development of Leeds Bradford International Airport will be supported… subject to …. environmental assessment and agreed plans to mitigate adverse environmental effects, where appropriate). In other words, the impact that you have highlighted is unacceptable, will not be mitigated, and the application should be rejected.

  4. If you want to, you can also bring into play national policies and laws, such as the NPPF - National Planning Policy Framework guidance on sustainable development, the Climate Change Act, but this guide does not go to that depth. There are a few quotes from the NPPF at the bottom of this guide.

 

 

The Planning Documents

Our guides have been written so that you don’t need to go into the application in depth but, you may want to! In the document section of the Planning Portal you will see hundreds of comments from the public. At the bottom of the list are the documents and drawings that make up the application. They are all dated 4th May and there are almost 200 of them. They are not in a helpful order but you can sort them by clicking on the ‘document type’ tab. It doesn’t put them in perfect order but it does put the application and background docs at the top, moving the comments to the bottom of the list.

There are several key documents:

  • SUMMARY OF PLANNING CASE - APRIL 2020 (V2) FINAL – the high level application.

  • PLANNING REPORT - APRIL 2020 FINAL – detailed application.

  • ES NON-TECHNICAL SUMMARY – high level coverage of environmental claims.

  • ES VOLUME I CHAPTER 01 INTRODUCTION – how they say the EIA was done.

  • ES VOLUME I CHAPTER 03 EIA METHODOLOGY – more detail on EIA.

  • ES VOLUME I CHAPTER 01 – 15 Various detailed environmental claims.

These ES documents are very important. A critical aspect of the application is the Environmental Impact Assessment (EIA). In a nutshell, the EIA is just an information gathering exercise carried out by LBA which enables the Council to understand the environmental effects of the development before deciding whether it should go ahead. The results of this are documented in the Environmental Summary (ES). These are the documents in the planning application starting ES. These need to be examined in detail, but you could choose whatever matters most to you. The ES covers Climate Change, Transport and Access, Air Quality, Noise and Vibration, Socio-economics, Biodiversity and Human Health.

On the Planning Portal, the document called ES VOLUME I CHAPTER 01 INTRODUCTION explains what each ES document covers.

 

NPPF [National Planning Policy Framework]

 

Finally, some quotes from the NPPF. It’s still the Core Strategy that is the key document but that was written under the guidance of the NPPF. It can be useful to back up your argument with this.

 

Paragraph 7:

The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.

Paragraph 8:

Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) an economic objective

b) a social objective

c) an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

© 2020 by Group for Action on Leeds Bradford Airport (GALBA)